Shipper Load and Count

Definition of Shipper Load and Count

Shipper Load and Count (SL&C, sometimes written SLC) is a designation placed on a bill of lading indicating that the shipper, not the carrier, loaded the freight and counted the pieces. A bill of lading (BOL) is the legal contract of carriage that accompanies a shipment. When the SL&C notation appears on it, the carrier is stating that it has not independently verified the contents, count, weight, or condition of the cargo. The carrier accepts the sealed trailer or container based on the shipper's declaration, and responsibility for the accuracy of that declaration rests with the shipper.

The notation is most common on full truckload and containerized freight, where the shipper loads goods at its own dock and the driver has no practical opportunity to open, inspect, or recount the load before departure.

Shipper Load and Count vs. SLAC, STC, and CLC

Several bill of lading notations are used interchangeably in conversation but carry different meanings. Getting them right matters because each allocates liability differently.

• SL&C (Shipper Load and Count): The shipper loaded the trailer or container and counted the pieces; the carrier did not verify the count. Common on domestic full truckload freight.
• SLAC (Shipper's Load, Stow and Count): A clause used on ocean bills of lading and sea waybills stating that the shipper loaded, stowed (arranged), and counted the goods before export, and the carrier did not check any of it. SLAC applies to containerized shipments, both full-container load (FCL) and less-than-container load (LCL), and does not apply to bulk cargo. It emphasizes both quantity and how the cargo was packed inside the container.
• STC (Said to Contain): The carrier is endorsing that the cargo description came from the shipper and was not verified. STC relates to the cargo description itself, whereas SLAC relates to quantity and packing. Under an STC notation, the carrier takes responsibility only for the number of pallets or containers listed on the bill of lading, not for the estimated units inside them.
• CLC (Carrier's Load and Count): The opposite arrangement. The carrier loads and counts the cargo and accepts liability for loss or damage caused by its own loading or counting errors.

One practical wrinkle affects international shipments: U.S. Customs and Border Protection does not accept the STC clause on bills of lading, so shipments bound for the United States now use Shipper's Load and Count instead. Under CBP's inward manifest rules (19 CFR 4.7a), generic "said to contain" descriptions are not accepted, so STC is little used on U.S. import documentation.

Why is Shipper Load and Count Used in Logistics?

SL&C serves three main purposes. First, it supports operational efficiency by removing the need for a driver to manually inspect and recount every load, which speeds dock turnaround. Second, it protects the carrier from liability for problems that originate during loading, before the freight is ever in the carrier's hands. Third, it preserves the integrity of sealed container shipping, where breaking a security seal to count contents would itself create risk and delay in international trade.

Key Components of Shipper Load and Count

Bill of Lading Notation

The SL&C notation must appear on the bill of lading itself. The exact wording carries legal weight: the phrase "shipper's weight, load, and count" or words of the same meaning is what triggers the statutory protection described below. A verbal understanding is not enough; the words have to be on the document.

Seal Integrity

Sealed trailers and containers use a numbered security seal applied by the shipper. The seal number is recorded on the bill of lading, and the carrier is responsible for delivering the load with that seal intact. An intact matching seal at delivery is strong evidence that the load was not accessed in transit.

Weight Declarations

The shipper provides the declared weight of the cargo. For international ocean containers, the Safety of Life at Sea (SOLAS) convention requires a Verified Gross Mass (VGM), which is the total verified weight of a packed container, before the container can be loaded onto a vessel. Under SL&C, the accuracy of that declared weight is the shipper's responsibility.

Documentation Requirements

Supporting paperwork such as packing lists, commercial invoices, and customs declarations accompanies SL&C shipments. This documentation substantiates the shipper's count and description if a discrepancy is later disputed.

Shipper Load and Count and the Law: The Carmack Amendment and 49 U.S.C. Section 80113

SL&C is not just a courtesy notation; it connects to specific federal law governing carrier liability in the United States.

Under 49 U.S.C. Section 80113(c), a common carrier that issues a bill of lading is not liable for damages caused by improper loading when two conditions are met: the goods were loaded by the shipper, and the bill of lading contains the words "shipper's weight, load, and count" or words of the same meaning. The same statute, at Section 80113(b), can also limit a carrier's liability for a load that does not match the bill's description, but only when the shipper loaded the goods and the carrier had no way to know whether the goods were received or conformed to that description. In other words, the statute is what gives the SL&C notation its protective effect.

Interstate cargo claims themselves are governed by the Carmack Amendment (49 U.S.C. Section 14706 for motor carriers, and Section 11706 for rail carriers). Carmack sets up a burden-shifting framework. To make a prima facie case (a claim supported by enough evidence to require the carrier to respond), a claimant must show three things, as established in Missouri Pacific Railroad Co. v. Elmore & Stahl (1964): the goods were tendered to the carrier in good condition, they arrived damaged or short, and the amount of the loss can be quantified.

Once the claimant makes that showing, the burden shifts to the carrier, which must prove it was free from negligence and that the loss was caused by one of five recognized defenses: an act of God, an act of a public enemy, an act or default of the shipper, an act of a public authority, or the inherent vice or nature of the goods. SL&C supports the "act or default of the shipper" defense, because improper loading or an inaccurate count performed by the shipper falls under it.

Apparent vs. Concealed Loading Defects

The protection SL&C provides has an important limit. It applies when the driver cannot inspect the load, for example when the trailer is sealed or the driver is denied dock access. If the improper loading was apparent, meaning the driver could have seen it and refused or corrected the load, the carrier can remain liable despite the shipper's negligence and despite the notation. Put simply, SL&C shields a carrier from defects it had no way to observe, not from problems in plain sight. The carrier also remains responsible for damage that occurs in transit; the notation addresses loading and count, not the carrier's duty of care on the road.

How Does Shipper Load and Count Impact Supply Chain Efficiency?

SL&C streamlines handoffs. Because the driver does not stop to inspect and recount, dock-to-dock transit is faster, trailer and driver assets turn more quickly across truckload and intermodal transportation moves, and carrier overhead per load falls. The shipper retains full control over how goods are loaded and secured, and sealed loads move through customs clearance more smoothly because the seal, not a manual recount, verifies that contents were not disturbed.

What Challenges are Associated with Shipper Load and Count?

The trade-off is that SL&C concentrates responsibility on the shipper, which introduces several risks:

• Liability disputes: When a consignee (the party receiving the shipment) reports a shortage, resolving whether the loss happened at loading or in transit can be contentious.
• Accuracy pressure: Any miscount at the dock becomes the shipper's exposure, so loading discipline and accurate inventory management matter more.
• Insurance complications: Cargo claims can turn on documentation quality, and thin records weaken a shipper's position.
• Fraud potential: A sealed load that is never independently counted can be exploited if internal controls are weak.
• System integration: Recording seal numbers, counts, and SL&C notations accurately across transportation management and warehouse management systems takes reliable process and technology.

Best Practices for Shipper-Loaded Freight

Both shippers and carriers can reduce disputes with a few disciplined habits:

• Put the SL&C notation, in the required statutory wording, directly on the bill of lading rather than relying on a verbal understanding.
• Apply a numbered security seal to full truckload and container shipments and record the seal number on the bill of lading.
• Have the receiver confirm that the seal is intact and that its number matches the bill of lading before opening the trailer or container.
• Keep loading evidence: dated photos or video of the loaded trailer, weight tickets, packing lists, and the recorded seal number. This documentation is what substantiates a shipper's count if a claim is filed.
• Note any visible exception at pickup or delivery on the bill of lading immediately, since apparent defects are treated differently from concealed ones.

Frequently Asked Questions About Shipper Load and Count

What happens if there's a shortage on an SL&C shipment?
The shortage is documented at delivery and, because the shipper loaded and counted the freight, a claim is typically directed at the shipper rather than the carrier. If the count was the shipper's responsibility and the seal arrived intact, the carrier's exposure is limited. If the loss appears to have happened in transit, the analysis shifts back toward the carrier.

Is SL&C the same as "Said to Contain" (STC)?
They are related but not identical. SL&C states the shipper loaded and counted the goods. STC states that the cargo description came from the shipper and was not verified by the carrier, and it relates to the description of the cargo rather than the count and packing. For U.S.-bound shipments, SL&C is generally used because Customs and Border Protection does not accept STC.

Can a carrier refuse an SL&C shipment?
Yes. A carrier can decline a load it suspects contains undeclared hazardous materials, or one presented with a damaged or missing seal, among other legitimate reasons.

How does SL&C affect 3PL fulfillment operations?
A third-party logistics (3PL) provider receiving an SL&C shipment should verify the seal, count on receipt, and document any exception at the point of receiving so that responsibility for a discrepancy can be traced correctly.

What documentation should shippers maintain for SL&C shipments?
Loading photographs or video, weight tickets, packing lists, and the recorded seal number. These records are the shipper's primary defense if a count or condition dispute arises.

What is the difference between SL&C and SLAC?
SL&C (Shipper Load and Count) is most common on domestic truckload freight and covers loading and count. SLAC (Shipper's Load, Stow and Count) is used on ocean bills of lading for containerized freight and adds "stow," meaning the shipper also arranged the cargo inside the container. SLAC applies to both full-container load and less-than-container load shipments but not to bulk cargo.

Does SL&C protect a carrier if the bad loading was visible?
Not necessarily. SL&C protects a carrier against loading defects it could not observe, such as those inside a sealed trailer. If the improper loading was apparent and the driver could have refused or corrected it, the carrier can still be held liable despite the notation.